Transfer Pricing Analysis Charges and Credits Sample Clauses

Transfer Pricing Analysis Charges and Credits. The transfer pricing analysis portion will be allocated on the principle of sharing costs equitably in proportion to the extent and costs of services used by each state. The Service budget costs for technical reviews will be allocated through an equal charge per state. The Service budget costs for economic reviews will typically be divided equally among the states participating in a specific taxpayer analysis. Costs may be further subdivided and proportionately reallocated among the states participating in a taxpayer case if the participating states use distinctly different levels of analysis, such as (a) an informal evaluation of the taxpayer’s position, (b) a formal economic and statistical analysis of a taxpayer transfer pricing study or (c) the formal analysis plus the development of an alternative transfer pricing position for use by a state. In such cases, the costs allocated to the states will be proportionate to costs incurred, will vary among states requesting different levels of analysis, but will be typically shared equally among states requesting the same level of analysis. The final transfer pricing analysis cost in a year for each state will be the sum of the equal share of technical review costs and its share of the costs of the economic analyses in which it participated and, if relevant, adjusted further for the level of analysis conducted for the state.
Sample 1
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